The consultation paper is wide-ranging and contains numerous proposals for expanding the reach of the legislation, to entities such as companies operating private ATM machines, certain forms of gambling, dealers of valuable items, company service providers, etc. It examines problems related to identifying beneficial ownership of companies and looks at interesting problems like politically exposed persons, the regulation of "structuring" (usually called "smurfing") and the sharing of information between the government and private parties.

Feedback to the paper must be provided by April 30, 2018. An excellent overview of the paper, by Jacqueline Shinfield of the Blakes law firm, can be found here. On a side note, the role of lawyers in the AML/ATF matrix, and particularly the balance of obligations to uphold the law and maintain client confidentiality, continues to be controversial.